South Korea MOTIE 36th Amendment to Strategic Items Export/Import Notification (Notice 2025-20) — quantum, AI-semis, 3D printing additions + procedural reforms

Mechanism

The Strategic Items Export/Import Notification (전략물자수출입고시) is the operative subordinate instrument under Korea's Foreign Trade Act that defines the goods and technologies subject to export licensing. Each "amendment" cycle is the principal vehicle through which Korea implements obligations from the four multilateral export-control regimes (Wassenaar, NSG, MTCR, Australia Group). The 36th amendment, issued as MOTIE Notice No. 2025-20, makes coordinated changes to articles 18, 23, 26, 30, 36, 50, 54-2, 56, 58-2, 59-2, 60-2, 89 and annexes 1, 2, 4 and 24.

Substantive content falls into three buckets:

1. List additions (21 items) — quantum computers, isotopes for quantum computing, ultra-low-temperature measurement equipment, high-temperature coatings, AI-class semiconductors, 3D-printing (additive-manufacturing) equipment, and related technologies. These mirror the 2024 multilateral plenary outputs and are already controlled in similar form by the United States (2024-09-05 BIS interim final rule on quantum / biotech / additive manufacturing) and several allied jurisdictions. 2. Russia-related humanitarian carve-out — exports to Russia of non-strategic medical-imaging equipment (diagnostic X-ray, radiographic imaging) are exempted from situational-licence requirements subject to prior notification. 3. Procedural modernisation — (i) where end-user verification is "extremely difficult", an intermediate counterparty may be deemed the final end-user; (ii) post-transaction reporting period extended from 7 days to 3 months; (iii) new self-disclosure system for non-compliance; (iv) individual export licences may be extended once beyond their original validity period.

A parallel 31 March 2025 amendment to the Investment-Promotion-and- Trade-Adjustment Act (IPTA) introduces a new MOTIE administrative coercive fine for non-compliance with overseas-M&A / JV orders — filed separately as a strengthening of the outbound-investment screening regime.

Downstream implications

• First standalone Korean export-control regime action in the IPTM

register: existing KR entries (K-CHIPS Act, Outbound Investment Screening, AI Basic Act, Semiconductor Special Act, Resource Security Special Act) all sit on the industrial-policy / inbound- finance side. This is the licensing-perimeter side.

• Aligns Korea with the US BIS Tier-1/2 export-control architecture

and the EU dual-use list; closes a previously porous flank in the trilateral chip-equipment perimeter, where Korean tooling, advanced packaging materials and quantum-computing precursors had no multilateral-equivalent licence requirement.

• Procedural softening (longer reporting window, deemed-end-user,

self-disclosure) is intended to be compliance-cost-neutral despite the list expansion — the trade-off is more items in scope but a less punitive process.

Open questions

• English-language MOTIE press release URL not yet located; the

motir.go.kr Korean-language notice page is the canonical primary source. (MOTIE was renamed to "Ministry of Trade, Industry and Resource" in mid-2025, hence the motir.go.kr / motie.go.kr domain duality — both currently resolve.)

• Watch whether Wassenaar 2025 plenary outputs (expected late 2025)

will trigger a 37th amendment in early 2026 — administrative pre-notice for the 37th amendment was already published and is visible on MOTIR's 행정예고 page.